Cox Data Labs is an independent organization that provides third party audits of Remote ID solutions to validate their conformance to the ASTM F3586-22 Remote ID Means of Compliance standard (in combination with F3411) — which is the accepted means of compliance to the U.S. FAA Remote ID rule.
As such, Cox Data Labs has completed the audit process of the “DroneBeacon” line of products by Bluemark Innovations B.V. and has issued a compliance certificate. This is a significant product accomplishment where, in addition to Bluemark submitting their declaration of compliance (DOC), they can now provide third party audited assurance of compliance to their customers and regulators.
Why should manufacturers have their products audited?
- It’s in the FAA Rule and in the Declaration of Compliance (AC 89-2, section 5.15) submitted by Manufacturers.
The FAA Remote ID rule states the following:- 14 CFR 89.515(b)(2): Audit requirements. A person responsible for the production of standard remote identification unmanned aircraft must cause independent audits to be performed on a recurring basis, and additionally whenever the FAA provides notice of noncompliance or potential noncompliance, to demonstrate the unmanned aircraft listed under a declaration of compliance meet the requirements of this subpart. The person responsible for the production of standard remote identification unmanned aircraft must provide the results of all such audits to the FAA upon request.
- 14 CFR 89.515(b)(2): Audit requirements. A person responsible for the production of standard remote identification unmanned aircraft must cause independent audits to be performed on a recurring basis, and additionally whenever the FAA provides notice of noncompliance or potential noncompliance, to demonstrate the unmanned aircraft listed under a declaration of compliance meet the requirements of this subpart. The person responsible for the production of standard remote identification unmanned aircraft must provide the results of all such audits to the FAA upon request.
- Be prepared if the FAA requests an audit report. As shown above, the FAA may request an audit report, and the manufacturer is obligated to produce it. Ideally, such an audit is performed prior to releasing a product in the US market since it reduces risk both to the manufacturer and their customers.
- Something may have been missed. The requirements for Remote ID are very technical and detailed and there’s always the risk of something falling through the cracks. A third party audit provides the opportunity for a “new set of eyes” to independently review the product design and implementation can provide the assurance of the compliance integrity to the manufacturer.
- Reduce the risk of being “de-listed”. As spelled out in FAA Advisory Circular AC 89-2, Section 8, the FAA can rescind an accepted DOC, which could essentially “ground” the product.
What is involved in a Remote ID audit?
The audit process is governed by ASTM F3365-19 – Standard Practice for Compliance Audits to ASTM Standards on Unmanned Aircraft Systems.
The audit starts by the Auditor meeting with the Manufacturer (either virtually or in person), gathering an understanding of the product line and creating an audit plan, statement of work (SOW with NDA and contract). The Auditor will then request design and test documents, component datasheets and interview engineering team members to get a clear understanding of the Remote ID design characteristics and testing already performed. The auditor will also perform many validations tests and will walk through every requirement in F3586-22 and requisite portions of F3411 to form checklists of each requirement and confirm evidence (either existing or through direct testing) to the satisfaction of each requirement. This process may take 1 to 2 months to complete depending on the breadth of product line and amount of testing necessary. Upon a successful audit, with any non-compliant issues properly addressed, the Manufacturer receives the full audit report and a (digitally signed) Compliance Certificate that will be listed on the Cox Data Labs website so that anyone can validate the successful audit proper attestation from the source.
Engineering Help:
If you’re a manufacturer navigating through the standards, in addition to getting copies of the standard, we recommend taking the e-learning course provided by ASTM. Additional engineering resources can be found by contacting Cox Data Labs, and certainly Cox Data Labs can audit your Remote ID solution in preparation for US distribution as described above.